the legal battle:

ITN vs LM

Request for Further and Better Particulars of the Reply


The legal documents so far:

The original letter from ITN's solicitors

Statement of Claim from ITN

The Defence

Two-Ten Statement in Open Court

The Reply

The Defendants' List of Documents

Request For Further and Better Particulars of the Defence

The Reply to the Request

>Request for Further and Better Particulars of the Reply


IN THE HIGH COURT OF JUSTICE 1997 I No. 139

QUEEN'S BENCH DIVISION

B E T W E E N :

  1. INDEPENDENT TELEVISION NEWS LIMITED
  2. PENNY MARSHALL
  3. IAN WILLIAMS

    Plaintiffs

and

  1. INFORMINC (LM) LIMITED
  2. MICHAEL HUME
  3. HELENE GULDBERG

Defendants

_____________________________________

REQUEST FOR FURTHER AND

BETTER PARTICULARS OF THE REPLY

_____________________________________

UNDER PARAGRAPH 2.3

Of: "(b) ·the depicted fence·formed part of an enclosure ("the enclosure") within which the men were being detained·The enclosure was almost entirely fenced in·"

Please specify:

  1. The approximate circumference of, or total length of the sides of, the alleged enclosure;
  2. The approximate total length of the depicted fence;
  3. What "part" (i.e. in approximate length) of the said circumference/total length of the said enclosure consisted of the depicted fence;
  4. (if 2. exceeds 3.) the nature and purpose of the remainder of the depicted fence;
  5. Whether the depicted fence surrounded some other area;
  6. (if the answer to 5 is in the affirmative):
    1. the nature of that other area (indicating what, if anything, was enclosed within it);
    2. whether the men were being filmed from that other area.
  7. Approximately how much (in length) of the said circumference/total length of the enclosure in which the men were located, was not "fenced".

Of: The whole of sub-paragraph (c)

Please specify:

  1. Whether it is admitted or denied that the Plaintiffs' reports gave the impression that Fikret Alic was in an enclosed area surrounded by the depicted barbed wire fencing (as alleged at paragraph 8 (viii) of the Defence);
  2. Whether Fikret Alic was "behind" or "in front of" the said depicted fence (i.e. whether he was inside or outside of the area surrounded by the fence).

GAVIN MILLAR

Served the day of 1998 by Christian Fisher of 42 Museum Street, Bloomsbury, London WCIA ILY, solicitors for the Defendants.